ML20058M326
| ML20058M326 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/09/1990 |
| From: | Eaton R Office of Nuclear Reactor Regulation |
| To: | Kriesberg J MASSACHUSETTS CITIZENS FOR SAFE ENERGY |
| References | |
| IEB-84-02, IEB-84-2, NUDOCS 9008100048 | |
| Download: ML20058M326 (9) | |
Text
r:
?,
's m
Docket No. 50-293 August 9, 1990 Mr. Joseph Kriesberg, Director Massachusetts Citizens for Safe Energy 37 Temple Place c
Boston, Massachusetts 0?111
Dear Mr. Kriesberg:
This letter is in response to your letter dated June 11, 1990 regarding Federal. Register notices to amend the operating license for Pilgrim Nuclear a
PowerStation(PNPS). Enclosure 1 responds to the seven questions you posed on the Logic System Functional Testing surveillance and Enclosure 2 responds to those same seven questions plus three additional questions that you posed on i.
the Core r.. Containment Cooling System surveillance.
I
,- this letter is responsive to your concerns.
Original Signed By:
Ronald B. Eaton, Project Manager Project Directorate 1-3 Division of Reactor. Projects 1/11 Office of Nuclear Reactor Regulation
Enclosures:
As stated cc: See Next Page MM Y Sp a PDI-L(A)
SIC OTSB PDI-3/PM}[M DIR(A)
BQ a n-SNe 1erry REmch REaton:me V rpes qg}/90 i
p/90 T/s- /90 f/C/90
/b /90 0FFICIAL RECORD COPY Document Name: PILGRIM AMEND OPERATING LICEN.
C
'Y0b?$$
g
f;
.c o.
L...:..
- s' DISTRIBllTION
-,.i.
. i.. ;..at,.,,Q PDI-3 R/F.
$Varga k'
Wessman BClayton REaton VNerses OGC (for info. only)
EJordan
$Newberry REmch ACRS(10)
JJohnson Rgn 1 l
4 i
I
\\
h l
l.
l l
i
o Mr. Joseph Kriesberg cc:
Mr. K. L. Highfill Mr. Richard N. Swanson, Manager Vice President of Operations /
Nuclear Engineering Department and Station Boston Edison Company Pilgrim Nuclear Power Station 25 Braintree Hill Park RFD #1 Rocky Hill Poad Braintree, Massachusetts 02184 Plymouth, Massachusetts 02360 Ms.. Elaine D. Robinson Resident Inspector Nuclear Information Manager U. S. Nuclear Regulatory Comission Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station RFD #1, Rocky Hill Road Post Office Box 867 Plymouth, Massachusetts OP360 Plymouth, Massachusetts 02360 Mr. Charles V. Barry Chairman, Board of Selectmen Secretary of Public Safety 11 Lincoln Street Executive Office of Public Safety Plymouth, Massachusetts 02360 One Ashburton Place Boston, Massachusetts 02108 Office of the Connissioner Massachusetts Department of Environmental Quality Engineering One Winter Street Boston, Massachusetts 02108 Office of the Attorney General 4
One Ashburton Place 20th Floor Boston, Massachusetts 02108 Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Boston, Massachusetts 02111 Regional Administrator, Region I U. S. Nuclear Regulatory Comission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. John Dietrich Licensing Division Manager Boston Edison Company P5 Braintree Hill Park l
Braintree, Massachusetts 02184 l
F i
V ENCLOSURE 1 QUESTIONS CONCERNING PILGRIM'S RE0 VEST FOR A CHANGE TO THE LOGIC SYSTEM FUNCTIONAL TEST TECHNICAL SPECIFICATIONS Ouestion #1 How often do other plants test this equipment? Please indicate the industry average and range.
Response
Pilgrim'srequestisconsistentwiththosegreviouslyapprovedforsimilar BoilingWaterReactors(BWRs)andwithBWR Standard Technical Specifications" (STS). The BWR STS required LSFT once per 18 months.
A survey of other BWRs indicates that Pilgrim is one of the last remaining plants with a 6 month Logic System functional Test (LSFT). Therefore, the LSFT amendment will make Pilgrim's technical specifications consistent with I
industry-wide testing frequencies for logic system functional test surveillances.
Question #2 How often does testing reveal equipment problems which require corrective actions?
Response
A search cf the document database for Pilgrim identified ten logic system relay failures during the period 1/1/8? through 4/30/86. The number of l
relay-hours for this period was calculated to be slightly less than 25 million hours. The resultant failure rate of approximately 4.0 E-07 failures per relay-hour i~ consistent with industry assumptions for per hour random coil s
failure rates.
Post of this failure history occurred prior to replacement of the original HFA relays with. Century Series 100 HFA relays in response to IE tulletin 84-02.
{
Question #3 How often do other plants test this equipment?
Response
As stated in Response #1, most other BWRs perform LSFT once per 18 months.
l
2 Question #4 j
is the equipment expected to last the lifetime of the plant?
Response
The original HFA relays were replaced with new Century series 100 HFA relays in response to IE Bulletin 84-02. The expected failure mechanism for HFA relays involves coil failure caused by exposure to the operating environment.
Based on accelerated agirg tests, the relays are expected to operate for at least 40 years.
Question #5 For how many cycles is the equipment desigred to last before needing replacement?
Response
As stated in Pesponse #4, the Century Series 100 HFA relay coils are expected to operate 40 years, exceeding the remaining life of the plant. They should not need to be replaced.
Question #6 How many total cycles would be required over the life of the equipment under the current and proposed technical specifications?
Response
A specific calculation of relay cycles over the life of the plant is not possible because of the variables that can result in relay cycling.
Pilgrim's operating license currently is scheduled to expire August 26, 2008. Under the current technical spacifications this 18 year period would require approximately 36 surveillance tests (18 years x 12 months /6 months). The change results is approximately 12 surveillance tests (18 years x 12 months /18 nonths), concomitant with a reduction of relay cycling.
Question #7 How long is the plant allowed to operate with this equipment inoperable?
Response
1 The LSFT relays are associated with a number of independent systems. The allowable cut of service time is determined by which system is affected.
It ranges between 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 7 days, i
e b
ENCLOSURE 2 l
l ECCS REDUNDANT L
SYSTEMS SURVEILLANCE GENERATED BY LIMITING CONDITIONS OF OPERATION l
Question #1 How often do other plants test this equipment? Please indicate the industry average and range.
Response
The Emergency Core Coo 11ng Systems (ECCS) for Boiling Water Reactors (BWRs) such as Pilgrim are ger.erally tested for surveillance purposes on a monthly frequency by plants with Technical Specifications similar to Pilgrim's. The Standard Technical Specifications, on which the proposed change to Pilgrim's Technical Specifications is based, define monthly as 31 days.
Pilgrim administrative 1y uses 31 days to define monthly for surveillance purposes, and is thereby consistent with plants using Technical Specifications similar to Pilgrim's.
Plants with Standard Technical Specifications test the equipment quarterly.
Question #2 How of ten does testing reveal equipment problems which require corrective actions?
Response
If a system is within its surveillance interval further testing should not reveal equipment problems requiring corrective actions. This assumption is
.the-foundation of establishing-surveillance intervals. The monthly interval for ECC systems was determined adequate to allow the early detection of system degradation to avoid system inoperability when the system is expected to respond.
The test intervals, allowable out-of-service times, and surveillance requirements for ECCS equipment and the diesel generators delineated in technical specifications are based on APED-5736, " Guidelines for Determining Safe Test Intervals and Repair Times for Engineered Safeguards" (April 1969).
This. study showed that the unavailability of standby redundant safety systems is a function of failure rate, repair time, and test interval! For the proposed change, PNPS failure rate effects cannot be quantifiabily measured until after the change is made, it is believed that reduced testing of redundant systems will reduce overall failure rates by reducing mechanical equipment wear. The experience of plants using Standard Technical Specifications support the belief that Pilgrim's continued reliance on the monthly surveillance interval without LCO induced testing of redundant equipment provides adequate assurance of ECCS equipment operability.
E 1
r b
J 2-j Ouestion #3 How often do other plants test this equipment?
~
Response
As stated in Response #1, plants using PWR Standard Technical Specifications test the equipment quarterly, and others test ECCS monthly. The monthly frequency is used at Pilgrim and is not affected by the proposed change.
Question #4 Is the equipment expected to last the lifetime of the plant?
Response
The ECCS equipment is expected to last the lifetime of Pilgrim.
As with any electro-mechanical device, this expectation involves maintenance of the equipment and the replacement or rebuilding of components found to be degraded or inoperabic.
Question #5 For how many cycles is the equipment designed to last before needing replacement?
Response
As stated in Response #4, the ECC systems are expected to last the life of the plant. 'The number of cycles required by testing is discussed in Response #6.
Cycle is currently defined for surveillance purposes by technical specifications as 18 months of operation. Some system components may be replaced or rebuilt from time to tima to maintain the equipment.
Question #6 How many total cycles would be required over the life of the equipment under the current and proposed technical specifications?
- Response The current monthly testing frequency results in 12 surveillance tests a year per. ECC system when the equipment is required to be operable.
Based on the 40 year plant life defined by Pilgrim's operating license, routine surveillance-testing results in 12 x 40 tests, or 480 cycles per system for the life of the plant due to testing.
E b.
~" '
m--
---a
n I
)
l l
The proposed change to ECCS technical specifications does not. change the monthly frequency, so routine surveillances should result in approximately 480 cycles for the life of the plant. Since the number of LCO induced surveillances is dependent on the inoperability of a system and how long the systems is out-of-service, the number of cycles cannot be calculated. The change will reduce or eliminate unnecessary cycling.
Question #7 How long is the plant allowed to operate with this equipment inoperable?
i
. Response ECC systems out-of-service periods are provided in Pilgrim Technical Specifications. The various periods are given below:
System Current Proposed LowPressureInjectionSystem(LCFI) 7 days 7 days low Pressure Injection (single pump) 30 days 7 days Containment Cooling System 7 days 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> High Pressure Core Injection (HPCI) 7 days 7 days Reactor Core Isolation Cooling (RCIC) 7 days 7 days Automatic Depressurization System (ADS) 7 days 7 days Diesel Generators 7 days 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Filled Discharge Pi p (HPCI, LPCI, RCIC) 7 days 7 days
[005 determin d by system, all of which are currently the same]
Ouestion #8 Please provide documentation of the " industry experience" referred to above.
(In the text of Massachusetts Citizens for Safe Energy Letter of June 11, 1990.)
Response
NUREG-0123,"StandardTechnicalSpecifications"(STS),wasissuedDecember29, 1980 to provide new plants with a standard technical specifications format.
The NRC further suggested that plants already licensed, such as Pilgrim, adopt STS under Multi-Plant Action (MPA) C-05.
HUREG-0123 does not require "immediate and daily thereafter" surveillance for redundant ECC system, and is the basis for Pilgrim's proposed change of March 15, 1990.
-4 NUREG-0123 is based on industry experience gained after Pilgrim was licensed.
I Nawer plants have been licensed to the requirements of NUREG-01?3 and others i
have adopted it since 1980. The NRC's experience with those plants has not I
resulted in the NRC reconsidering it non-inclusion of "immediately and daily thereafter" in NUREG-0123, or reconsideration of the suggestion that earlier plants adupt the change.
Question #9 Please indicate why this problem cannot be corrected with modified procedures and/or improved worker training.
Response
There is no indication that Pilgrim's March 15, 1990, request to amend the ECC technical specification requirements was made to correct a problem stemming from procedures or worker training.
The March 15, 1990, request is indicated as being made to bring Pilgrim's technical specifications into conformance with Standard Technical Specifications (asrequestedbytheNRCinMPAC-05).
Incide tal to the change, this does reduce potential system misalignment by reducing the surveillances of redundant systems outside their normal frequency.
It was also proposed tn minimize component wear inherently associated with the operation of any electro-mechanical device.
Puestion #10 Please indicate what the basis is for the NRC's claim that reduced testing doesn't reduce one's confidence that a given system will be available when necessary.
Response
The basis of, normal operations is that equipment within its surveillance interval is operabic.
Since ECC systems are designed such that the inoperability of one system does not impact the operability of any of the other systems, redundant system testing currently induud by an t.C0 does not affect the level of confidence in a system's availabilitv.
The proposed change does not reduce routine surveillance testing; it only 1
affects surveillance testing required by the inoperability cf an independent system.
If confidence that routine surveillances of systems ensures system operability between surveillance tests such that plant operation is permissible, a similar confidence level exists that a system within its l
interval is operable when an independent system is made or found inoperable.
.